Data Protection Privacy Policy
Last Updated: 1st February 2020 |
This data protection notice provides information about the ways in which INNOVU Insurance Ltd T/A INNOVU Insurance collects and uses personal data. For the purposes of data protection legislation, The Data Controller is INNOVU Insurance Ltd T/A INNOVU Insurance, The Arc, Drinagh, Wexford, Y35 RR92. Our Data Protection Officer can be contacted by email at: dpo@innovu.ie. “Data Controller” and “Personal Data” have the meaning given in the General Data Protection Regulations 2018. We have appropriate safeguards in place, in accordance with our data protection obligations, for the protection of any Personal Data which we process. Our security controls are aligned to industry standards and good practice, providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information. Additionally, we ensure that our employees remain aware of our data protection obligations and are required to undertaken annual training. We take the protection of your privacy and the confidentiality of your personal information (“Personal Data”) seriously. This Notice sets out how we meet our obligations regarding data protection and the rights of our customers, prospective customers, and former customers (“Data Subjects”) in respect of their Personal Data as defined under relevant data protection legislation (including the Data Protection Acts of 1998, 2003 and 2018 [“the DPA”], the General Data Protection Regulation effective from 25 May 2018 [“the Regulation”] and any subsequent data protection legislation). Please read this Notice carefully as this sets out how any personal data we collect from you or data that you provide will be processed. The Regulation defines Personal Data as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. INNOVU Insurance is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal. |
1. Information we collect |
When you provide personal information we will only use this information for the purposes described at point of collection e.g. providing an insurance quotation or employment application. Other people’s Data: As well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. NOTE: If you are providing information about another person, we expect you to show them this data protection notice and ensure that they have given you their permission to provide this information to us to enable INNOVU Insurance provide a quotation. If they have any concerns please ask them to contact us as outlined in ‘Contact us’ section. |
2. How we collect information about youWe will collect information from you, your agents or representatives, as well as information received from:
We will process Personal Data for and only to the extent necessary for the specific purpose(s) outlined in this document. |
3. How we will use your personal information |
Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your insurance cover and the provision of any ancillary risk management services
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4. Legal Basis |
We will process special category and criminal conviction data we collect about you for the performance of our contract with you, which is deemed to be necessary for reasons of substantial public interest. This allows us to quote for and provide you with insurance products and services, to process claims and renewals and to administer your policy. Where Personal Data about you is obtained from publicly available sources, we will only use such data fairly, meaning for legitimate purposes as would be anticipated of (and reasonably expected as) the activities of an insurance broker, or employee benefits consultant as appropriate, and not further processed in a manner that is incompatible with those purposes.
5. Sharing your dataWe may make your information available to third parties with whom we have a relationship to provide services on our behalf. We will only provide to those third parties the information that is necessary for them to perform the services and we take measures to protect your information. The selected third parties that we may share your information with may include:
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6. Data Retention |
Data will not be held for longer than is necessary for the purpose(s) for which it was obtained. INNOVU Insurance will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance |
7. What happens if I do not provide my data? |
If you do not provide information we may not be able to:
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8. Profiling/Automatic Decision Making |
Profiling; The main categories are
Risk Profiling To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions. Profiling for marketing purposes Where we contact you about other services, we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs. We process information you give to us and information we receive about you from other sources. Note that we do not disclose personal information about you to third parties. Establishing affordability and providing quotations for financial services products.
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9. Opting out |
We want to make it easy for you to make your own choices as to what information you receive from us and how we contact you. Therefore, whether you are an existing, former or prospective client we will always remind you of your right to opt out of future marketing related communications each time we send such correspondence to you. You can elect not to receive any marketing related communications from us at all, or request that you only receive certain types of communication. Please see below for contact details. 10. Your Rights regarding your Personal DataINNOVU Insurance facilitate you, our customers rights in line with our data protection policy and the subject access request procedure which is available on request. At any point while we are in possession of, or processing your personal data, you, the data subject, have the following rights:
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data. If you wish to exercise any of your data rights, you can contact us at INNOVU Insurance, The Arc, Drinagh, Co Wexford Y35 RR92, or at email: dpo@innovu.ie |
11. Data Security |
We have appropriate measures in place to ensure that users’ personal details are not misused, accidentally destroyed, lost or altered when we process your data either by electronic or paper means. Occasions will arise when customer information is passed outside Innovu Insurance to our trusted third-party suppliers, but they will only act upon instruction from Innovu Insurance in order to perform the services required. . |
12. TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE EEA |
The Data Controllers may from time to time transfer (‘transfer’ includes making available remotely) Personal Data to countries outside of the EEA where this is necessary for us to provide our services to you. This will take place only if one or more of the following applies:
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13. Additional Processing |
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information to you prior to processing this data.
14. ComplaintsIn the event that you wish to make a complaint about how your personal data is being processed by INNOVU Insurance or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer
Data Protection Commission
15. Contact UsYour privacy is important to us. If you have any comments or questions regarding this notice please contact dpo@innovu.ie We may change the privacy notice from time to time. When such a change is made, we will post a revised version online. It is your responsibility to review this privacy notice periodically to keep up to date with any changes. By using our services you agree to this privacy notice. |